FAQs on the mediation of financial and insurance products

1. Do I need a permit to mediate?

Yes. For the professional mediation or consultancy of insurance, investment funds, or real estate loans, a permit according to §§ 34d, 34f, 34h, or 34i GewO is required.

Which permit is necessary depends on the products and the type of activity. The responsible licensing authority – this can be the German Chamber of Commerce and Industry (IHK) or a governmental institution such as the trade office or similar – examines the prerequisites and issues the permit.

2. What prerequisites must I meet for the permit?

The basic requirements include:

• Reliability
• Orderly financial circumstances
• Proof of expert knowledge
• Professional indemnity insurance in the prescribed minimum amount
   

3. Is the permit alone sufficient to operate?

No. In addition, registration in the respective mediation register is required. Only after the registration can intermediaries operate on the market.

4. How does the registration in the register work?

Registration is done through the IHK in the so-called mediation register. The essential details – such as permit type, registration number, and contact data – are then publicly accessible at www.vermittlerregister.info.

5. Which details are visible in the register? What is the purpose?

Among others, the following are displayed:

• Permit and registration number
• Mediation type (e.g., brokers, representatives, investment brokers, fee advisors)
• Address and contact details
• responsible IHK

The register is intended to enable the public – especially investors, insurance companies, as well as loan borrowers and lenders – to verify the licensing and scope of activity of those required to register.

6. Must changes to my data be reported?

Yes. Changes such as name, legal form, address, indemnity insurance, or scope of activity must be reported promptly to the responsible licensing authority to ensure the register's data remains current.

7. What applies to insurance companies with employed intermediaries?

Insurance companies registered with the Federal Financial Supervisory Authority (BaFin) can directly enter their tied insurance intermediaries into the insurance intermediary register (VVR).

For the application of the required DIHK login, an editable form is available:
Application for Login (only available in German) (PDF, 55 KB)

Companies under BaFin or state supervision can also apply for read access to the so-called deletion list of the VVR (§ 11 para. 3 Trade Regulation Act – GewO). This access is exclusively intended for insurance companies not yet participating in central electronic data transmission.

The DIHK also provides a corresponding form for this:
Application for Access to the Deletion List (only available in German) (PDF, 67 KB)

8. How can I check if someone is registered?

Through the public register at www.vermittlerregister.info, you can check whether a person or company has a valid permit and registration. The DIHK collects quarterly statistics on the entries in the register. 

9. What happens if I mediate without a permit or registration?

The activity without the required permit or register entry constitutes an administrative offense and can be punished with significant fines. In severe cases, the activity may be prohibited.

10. Do insurance intermediaries have to continue their education?

Yes. Intermediaries must annually provide proof of their continuing education hours to remain professionally up-to-date. Together with the Federal Financial Supervisory Authority (BaFin), the DIHK has developed questions and answers regarding the continuing education requirements of insurance intermediaries. You can find the FAQs for download on the BaFin website.

11. Are there special features for group insurance contracts?

Companies that want to provide their employees with uncomplicated insurance coverage through group insurance contracts must observe several aspects. Following a decision of the European Court of Justice (ECJ) in autumn 2022, it is conceivable that providers or even insured parties act as insurance intermediaries – with far-reaching consequences. Together with the IHKs and the Federal Financial Supervisory Authority, the DIHK has developed a guide on the implications of the ECJ judgment on intermediary status in group insurance, which helps with the delineation:

Supervisory Notice on the Intermediary Status in Group Insurance Contracts (PDF, 154 KB) (only available in German)